QOP-42-01 Control of Documents - Quality Coach

QOP-42-01Control of DocumentsIssued by: Quality Assurance Effective Date: 6/6/2011 Rev. A Pg. 1 of 9Approved: 6/6/2011 5:48 PM - Alan Halko, Quality ManagerThis procedure provides general rules for controlling different categories of documents, anddocuments in different media.The procedures is based on the assumption that the ISOXpress system is used for controllingmost of the documents, but that there also are other local departmental document controlsystems that are separate from ISOXpress, for example, for controlling engineeringspecifications and drawingsIf you don’t generate much engineering or other product-related documentation, it shouldbe possible for you to control all your documents through the ISOXpress system. In this casedelete any references to the ‘other control systems’.IPURPOSEThe purpose of this procedure is to provide for a system and instructions, and to assignresponsibilities for the establishment, review, authorization, issue, distribution, and revisionof controlled documents.IIAPPLICATIONThis procedure applies to the following categories of documents:Make sure to coordinate this list with Quality Manual Section 4.2 where these documentsare also listed and defined. Edit the list to be appropriate for your company, for example, ifyou don't install or service your devices, delete any references to installation and servicing. Quality manual; Operational procedures; Work instructions; Forms; Device, labeling and packaging specifications; Manufacturing, installation and servicing specifications; Quality assurance procedures and specifications; and Standards and codes.IIIPROCEDURE1 ISOXpress document control system1.1 Whenever possible and practical, documents are controlled and distributed through theISOXpress document management system, consisting of two modules: Document Menu andDocument Control.1.2 The Doc Menu module is for distributing company’s documents. From this module users candisplay and print documents, but cannot change them. When available, users can alsodownload a (master) file associated with the document. Only approved and releaseddocuments are available in this menu. Users can view only those document folders

QOP-42-01 Control of Documents Rev. A Pg. 2 of 9(categories) for which they have explicit viewing permission (set up from the Doc Controlmodule)1.3 Documents have automatically generated headers and footers with information about theirrevision level, effective date, issuing authority and approval status. This information ispicked up directly from the document control record (maintained in the Document Controlmodule), ensuring that it is always accurate and up to date.1.4 The Document Control module is for creating and managing documents, to include: Creating new documents and document revisions, Organizing documents in a folder tree, Approving and releasing documents, and Controlling document viewing and editing permissions2 Other document control systems2.1 Some categories of documents are controlled locally by the departments that establish and/oruse the documents, and are not entered in the ISOXpress system. This specifically applies to: Engineering design documents, specifications and drawings;If you decide to exclude engineering documents form ISOXpress (which would beappropriate in some cases), the engineering department must then have their own documentmanagement system that complies with ISO 13485 and general requirements of thisprocedure. They would also need to have a separate procedure or work instruction definingtheir system. Various confidential documents regarding legal, financing, personnel, contracts and othersuch confidential documents and records.Edit this list of excluded the types of documents as applicable in your company.3 Categories of controlled documents3.1 Quality System Records (QSR): Documents defining the quality management system, inparticular the quality manual, operational procedures, and work instructions that are notspecific to any particular device or its manufacturing process, are referred to as QualitySystem Record (QSR). QSR documents are established and controlled following the samerules that generally apply to all controlled documents, e.g., as defined in this documentcontrol procedure.Documents in this category include: Quality System Manual (QM): This top-level document defines the company's qualitypolicies and quality objectives; defines the scope of the quality system, including detailsand justification for any exclusions (refer to QM Section 1.4); describes the overall qualitysystem, its processes, and their sequence and interaction; and references applicableoperational procedures. Quality System Operational Procedures (QOP): These are second-level documentsdefining specific quality system processes. Operational procedures explain the what,when, who and how for a process, and define what records must be established to

QOP-42-01 Control of Documents Rev. A Pg. 3 of 9document the results. Operational procedures are code numbered QOP-SS-NN. QOPstands for Quality Operational Procedure, SS is the section in the quality manual to whichthe procedure pertains, and NN is the consecutive number of a procedure pertaining to thesame section. For example, QOP-75-03 is the third operational procedure pertaining toQM Section 7.5. Quality Forms (QF): These are usually one-page manual forms providing a blanktemplate for establishing a record. Forms are code numbered QF-SS-NN-M. QF stands forQuality Form, SS-NN is the code-number of the procedure to which the form pertains, andM is the consecutive number of a form pertaining to the same procedure (to distinguishbetween different forms associated with the same procedure). For example QF-82-01-2 isthe second form associated with procedure QOP-82-01.Forms are established as separate documents, but are associated with specific proceduresthrough the numbering system.3.2 Device Master Records (DMR): Documents that define the device, manufacturing process,and quality assurance specifications are organized into a file and/or are referenced in anindex called a Device Master Record (DMR). Operational Procedure QOP-42-02, DeviceMaster Record, defines how DMRs are established and maintained. DMR documents areestablished and controlled following the same rules that generally apply to all controlleddocuments, e.g., as defined in this document control procedure.Although the concepts of DMR and QSR are defined in CFR 820.181 and 820.186, ISO13485 also requires the same types of documents. The difference is in how the documentsneed to be organized rather than what controlled documents are actually required.Documents in this category include: Product specifications: These documents include component, subassembly, assembly,packaging and labeling drawings and specifications; bills of materials (or lists ofingredients); compositions; formulations; wiring and piping diagrams; softwarespecifications; user manual, packaging artwork, and other such documents defining theproduct and its packaging. For some contracts these documents may be of external origin,i.e., supplied by customers.Refer to these documents as is customary in your industry and company. For example, inyour industry, specifications may be called data sheets, and there may be no drawings butdiagrams. If labeling or packaging specifications are not applicable, delete these referencesaccordingly. Whatever the format and names, this clause refers to documents defining yourproduct. If you never receive such documents from your customers, delete the last sentence. Manufacturing specifications: Documents under this category include process flowcharts; diagrams of process/assembly lines; specifications for equipment, tools, and molds;setup procedures; operator instructions; machine maintenance procedures; blank workorders (job travelers), nonconforming product/process forms, and other reporting forms;and other such documents defining the manufacturing processes and the manner ofproduction.As written now this clause mentions too many things. This is intentional to give youexamples of what types of documents to include. You must edit this clause to include only thetypes of documents that exist and are actually used in your company. For example, don’tmention molds if you don’t use molds, and don’t include setup procedures if they are not

QOP-42-01 Control of Documents Rev. A Pg. 4 of 9relevant. Quality control procedures and specifications: Documents in this category includeprocess control specifications/charts; control plans, instructions and acceptance criteria forincoming, in-process, and finished product inspection and testing; procedures andacceptance criteria for the verification of packaging, labeling, installation, and servicingactivities; blank forms for inspection/testing reports and other quality records; releasedocument review list; and other such documents defining how products andmanufacturing processes are controlled and verified.Delete items that are not applicable. For example, if you don't use SPC, delete references toprocess control; if you don’t do labeling, installation or servicing delete references to theseactivities; if you don’t use control plans don’t reference them, etc. Work Instructions (WI): The purpose of work instructions is to guide personnel inperforming specific tasks, such as carrying out and controlling a production processes(process operator instructions), handling products, calibrating measuring equipment,conducting tests or inspections, etc.Give examples that are relevant in your company. Standards and codes: These are international, national and local regulations, standards,and codes that define operational, quality and product requirements.If you don’t use any standards and codes you can delete this whole clause (remember to coordinatewith Part II Application and with Clause 4.2.1.1 in the Quality Manual). If you are using only oneor two, you could reference them here directly. If there are many different standards, you can justleave this clause as is and list the actual standards to be controlled in the document controlmaster list.4 Document Identification4.1 In the ISOXpress control system documents are identified by: Document ID Title Revision level Issuing authority Effective date Review/Approval authority4.2 ISOXpress system automatically generates a header with document control information (ref.to 4.1 above) and merges the header with the document.4.3 In other document control systems documents are, at a minimum, identified by:These are generic requirements that apply to all types of controlled documents. For specifictypes of documents, such as engineering drawings, for example, your internal identificationrequirements may be much more comprehensive. It is usually better to cover such specialrequirements in separate procedures or work instructions, rather than complicating thisgeneral document control procedure. Unique title and/or code/number,

QOP-42-01 Control of Documents Rev. A Pg. 5 of 9 Effective date and/or revision level, and Identification of the issuing/approving authority.The specific format and method for applying the identification depend on the type ofdocument and whether the document is in paper or electronic medium.4.4 At a minimum, all controlled documents are identified with respect to their revision level bythe effective date. In addition, alphanumerical identification of revision level is applied forsome types of documents to facilitate their management.The purpose of this clause is to establish the principle that when there is no numerical oralphanumerical revision level identified on a document, the date is considered to be therevision level. Edit this clause to accurately define how revision level of engineeringdrawings and specifications is identified.5 Initiating new documents and revisions5.1 Personnel on all levels are encouraged to identify the need for, and propose development ofnew procedures, work instructions, workmanship standards, and additional product-relateddocuments. Personnel are also encouraged to critically evaluate the documents they use andrequest revisions to correct errors and inconsistencies.5.2 Anyone in the company may request the issue of a new document, or a revision of anexisting document. The person wishing to initiate a document or a revision submits a draft ofthe proposed document to the manager or supervisor responsible for issuing this type ofdocuments (or, if revision, to the author of the original document). The manager responsiblefor approving and issuing the document may revise or reject the draft. Regardless of whoinitiates a document, the responsibility to review, approve, and issue the document alwaysrests with the manager authorized to issue the particular type of documents.6 Initial issueIf you already have an established process for initiating documents and requestingrevisions, rewrite this clause to accurately describe your process. Larger companies oftenhave special forms for requesting new documents and changes, but this is not necessary in asmall company.6.1 Prior to issue and release, documents are reviewed for adequacy, correctness, and conformitywith company policies.6.2 Approved and released documents are identified with the name (or initials) of the issuing,and where appropriate, approving authority; and the effective date. In the ISOXpress system,this information is entered into the Document Control Record, and can be seen in thedocument header.6.3 In paper (hard copy) documents, hand-written or "wet" approval signatures on documents arenot required, although they may be used for particular types of documents (usually forexternal communication).Edit if you disagree with this statement, but remember that requirement for “wet” or evenfor “electronic” signatures makes it more difficult to control and distribute documentselectronically. You should not require signatures when there are no real security

QOP-42-01 Control of Documents Rev. A Pg. 6 of 97 Revisionsconsiderations that warrant it.7.1 Changes to documents are reviewed and approved by the same function that approved theinitial document, unless specifically designated otherwise. The issuing of revisions followsthe same procedure that applies to the issuing of initial documents.7.2 Revised documents are formally issued when the issuing/approving authority and the neweffective date are identified in the document (as well as the new alphanumerical revisionlevel, where applicable).This defines how draft documents are distinguished from approved and released documents.Edit to accurately reflect how this is done in your company.7.3 When paper (hard copy) documents are changed by handwritten corrections without thedocument being re-issued on a higher revision level, the changes are signed and dated. Whenmultiple controlled copies of a document are distributed to different locations, all copies arechanged. Paper printouts of documents that are distributed electronically (e.g., are availableon the network) may not be changed by handwritten corrections.This pertains to the so-called redline corrections. If such corrections are not allowed inyour company (a good idea), change this clause to simply state that correcting and alteringdocuments by hand is not permitted. Otherwise, edit to accurately describe how handwrittenredline corrections are controlled in your company.8 Distribution of initial issues and revisionsYour company may have a much more elaborate system for distribution of paper (hard copy)documents. For example, you may have a system of transmittal letters (or cover sheets) thatthe recipients sign and return upon receiving new or revised documents; and you mayrequire that obsolete copies of superseded documents be formally returned. Such formalsystems are not explicitly required, but if you are already doing these kinds of things,document them here in this procedure.When distributing revised documents, the recipient should be informed what has beenchanged and what is new in the document. In a paper document tt can be a note on themargin, highlighted text, or a cover sheet/transmittal letter summarizing changes. You couldalso have a “Change History” matrix permanently included in the title page of thedocument with summaries of changes for each new revision (this would also be suitable inan electronic document uploaded to ISOXpress). None of these methods are documented inthis procedure because the ISO 13485 standard does not explicitly require you to have sucha system for communicating changes. However, it was required in the previous, 1996 editionof the standard, and many auditors still expect some type of change briefs.8.1 Documents are distributed to personnel and locations where they are needed to correctlycarry out, manage, and verify the pertinent processes, activities and jobs. Electronicdocuments are accessed from computers and/or terminals, or printouts of electronicdocuments are distributed for one-time use. Paper (hard copy) documents are distributed tospecific recipients and/or document stations.8.2 Revisions of paper documents are distributed to the same personnel and locations as theoriginal issues. Upon receiving a new, revised copy of a document, the recipient is required

QOP-42-01 Control of Documents Rev. A Pg. 7 of 9to remove and destroy the old, superseded version of the document. Maintainingunauthorized files with superseded revisions of controlled documents is prohibited.Some auditors will want to see something more than just such a policy statement thatrecipients must destroy the superseded versions of revised documents, and that maintainingunauthorized files with obsolete documents is prohibited. Ideally, there should be a systemthat ensures the removal of obsolete documents without relying on the recipientremembering to do it. Often the recipient is not interested in giving up the old documentbecause he made some hand-written notes on it (which should be prohibited anyway) or heis simply a pack rat. For example, it could be a system where someone will physicallydeliver the revised document in “exchange” for the old one; or where old documents mustbe brought or sent back to the document control function who tracks the return status foreach recipient. In a small company with only one location the most practical system wouldprobably be having someone actually go out there and retrieve the old documents.Taking the minimalist approach this procedure does not define any specific system forensuring the removal of obsolete documents and relies instead on people following thestated policy. If this is questioned by an auditor, especially if there are actually identifiedinstances of obsolete documents being found where they should not be, you can then respondwith developing and implementing a more robust system. In any event, this potentialproblem is only relevant to paper-controlled documents. With more and more documentsbeing controlled electronically there is a good chance that, especially in a small company,this issue will not come up at all.8.3 Electronic documents are uploaded to the ISOXpress server or are posted on the network andare available for viewing and printing from ISOXpress Doc Viewer or relevant computersand terminals. When a document is revised, the old edition is taken down from ISOXpress orthe network and is substituted with the revised document.9 Master list9.1 Any document control system maintains a master list of controlled documents. The listidentifies each issued document by its code/number, title, approval/issuing authority,effective date, and revision level, as applicable. For paper documents a distribution record isalso maintained.9.2 In the ISOXpress system, such a master list is maintained in the Doc Control module.If you produce a large number of engineering documents (drawings, specifications, etc.),you would probably want to have a separate and independent control system for thesedocuments, and thus also a separate control list. You could define a separate system forcontrolling engineering documents by adding a special section to this procedure, or byestablishing a new additional procedure or work instruction.10 Customer engineering documents and changesThis is mostly relevant only for subcontractors. If you don't receive and/or use technicaldocuments from customers or other external sources, you can delete this section.10.1 Engineering documents (standards, specifications, drawings, samples, etc.) and changesreceived from customers are logged in the Customer Engineering Documents (CED) Log.You can also log these documents in special customer or contract-related logs or projectbooks, etc. Whatever you do you must have an easily accessible record of engineering

QOP-42-01 Control of Documents Rev. A Pg. 8 of 9documents received from customers and their current status (revision level, approval statusand the date on which they were implemented in production).Whatever the scope of this log, it would be most practical to have it on a computer (an Excelspreadsheet or a database).10.2 After the documents are logged, they are forwarded for review and approval. The scope ofthe review includes checking for correctness of the document and its revision level,identification of all changes (for revisions), and verification that the document has beenapproved by the customer's issuing authority. If any ambiguities or errors are detected, thecustomer is contacted. Approval of external documents is indicated by the approval date, thename or initials of the person approving the document, and a note stating that the documentis approved for production.10.3 Only documents approved internally by an authorized function may be used in production orinspection activities.11 Uncontrolled copiesIf you regularly receive customer documents, you probably already have a system forlogging, reviewing and maintaining these documents. Edit and further develop this sectionto define your system as it is implemented. Jus make sure that it includes the review andapproval activities, as in 8.2.11.1 Printouts of electronic documents (ISOXpress server and network files) are not controlledand must be destroyed after one-time use.11.2 Documents issued to personnel and outside parties who are not affected by the document, butneed a copy for information only, are stamped UNCONTROLLED across the title page.Such documents are not followed up with revisions. Uncontrolled copies of documents maynot be used by personnel or outside parties who manage, perform, or verify work that isdirectly affected by the document.12 Retention of obsolete documents12.1 At least one copy of obsolete controlled documents is retained. This is to ensure thatdocuments used in the manufacture of medical devices are available after the devices havebeen commercially distributed.12.2 Obsolete documents are retained for at least the lifetime of the device, but not less than theretention period of any resulting records (refer to Operational Procedure QOP-42-03, Controlof Records). In any case the retention period may not be less than two years from the date thedevice was released for commercial distribution, or as specified by relevant regulatoryrequirements.The two years minimum retention period is required by 21 CFR Part 820.180. If you areonly implementing ISO 13485 you can delete this sentence.12.3 For paper (hard copy) documents, retained copies of obsolete documents are stampedOBSOLETE and are kept in special files separate from active documents.12.4 For electronic documents, e.g., files on network drives and ISOXpress server, obsolete

QOP-42-01 Control of Documents Rev. A Pg. 9 of 9documents are either: Printed out, stamped ARCHIVE and are kept in special files as paper (hard-copy) archive,while the electronic files are deleted; or The documents files are downloaded from the ISOXpress server or are removed from thenetwork, and are stored in permanent electronic archiving media (removable disks, tapes,etc.).IVREFERENCED DOCUMENTS Operational Procedure QOP-42-02, Device Master Record Operational Procedure QOP-42-03, Control of RecordsVASSOCIATED RECORDSIn addition to the records listed below, many companies also have a form for requesting theestablishment of a new documents or revision of existing documents. This form wouldusually be called "Document Initiation/Change Request Form." I did not include this formbecause you can get by without it, and in a small company it would unnecessarilybureaucratize the system. But if you like the idea, make up such a form and include it in yoursystem. Lists of controlled documents and document control records: Lists of issued controlleddocuments and records with their control information. Documented in the ISOXpresssystem > Document Control. Records of received customer engineering documents: Customer EngineeringDocuments (CED) Log for recording the receipt of customer engineering documents andchanges.A template for this log is not included in this documentation. It would only be relevant if youare a subcontractor and regularly receive drawings from your customers. Refer tocomments under Section 10 of this procedure.FOR MORE INFORMATION AND BUYING OPTIONSPlease follow the link below to learn more and purchase the template documentationISO 13485 FDA QSR (21 CFR 820) Quality Manual Templateshttp://www.qualitycoach.net/shop/shopexd.asp?id=5860